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Sanctions: NCA issues red alert on Gold-based Financial and Trade Sanctions Circumvention

Thursday, 9 November 2023

The Treasury advises that on 8 November 2023 the UK's National Crime Agency (NCA) issued a red alert to financial institutions and other members of the regulated sector warning that Russia is using gold as a means to undermine the impact of the UK sanctions regime. The statement to the alert reads:

‘Gold is a significant income stream for Russia’s war effort – one of the highest by value after oil and gas, and worth £12.6 billion to the Russian economy in 2021. Today the UK's Foreign, Commonwealth and Development Office (FCDO) has sanctioned a number of individuals and entities operating in and supporting Russia’s gold sector.

Given the importance of the UK to the gold market, the NCA is warning of deliberate attempts are being made to launder sanctioned gold to mask its origin so that it can be hidden in supply chains and sold in the UK and around the world.

Gold exported from Russia since 21 July 2022 is increasingly being shipped to countries that do not apply sanctions on Russian gold. Once melted down and recast or refined, the origin of gold cannot be determined by examination, as any hallmarks are lost. Imports of mined gold can also be easily disguised. By masking the origin, new Russian gold can then be sold on to another country who may be unaware of the true origin.

Adrian Searle, Director of the National Economic Crime Centre at the NCA said:

‘Sanctions evaders undermine UK national security, working against our foreign policy objectives which promote international peace and security, and the rule of law. With the robust implementation of controls by the UK financial sector and our international partners, to identify and disrupt sanctions evasion, we have seen consequent attempts to use gold to circumvent the sanctions regime.

‘London’s precious metals market sets the global standard for the quality of gold. The sector plays a key role in supervising the trade and improving record keeping to boost the integrity of the supply chain. This alert will aid efforts, in partnership with the regulated sector, including the banks and high value dealers, to ensure that sanctioned individuals or those who represent them cannot use gold to circumvent UK sanctions.’

The London Bullion Market Association (LBMA) accredits gold refineries around the world. It sets the standards for what constitutes ‘London Good Delivery’ (LGD) gold which has become the ‘de facto’ global standard. LBMA accredited refineries account for 85-92% of annual global mined gold production.’

The alert has been issued to the regulated sector, including banks, high value dealers and lawyers, and is available read.

If you have any questions about this notice, please contact

Further details of the sanctions regime related to Russia and links to other financial sanctions regimes may be found on the Customs and Excise pages of the Isle of Man Government website.

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